This document was prepared on
behalf of the National Treasury Employees Union Chapter 280 by
Chapter Senior Vice-President J. William Hirzy, Ph.D. For more
information please call Dr. Hirzy at 202-260-4683. His E-mail
address is <hirzy.john@epa.gov>

EPA's Union of
Scientists' "WHITE PAPER"

Why Union
Opposes Fluoridation

May 1, 1999

The following
documents why our union, formerly National Federation of Federal
Employees Local 2050 and since April 1998 Chapter 280 of the
National Treasury Employees Union, took the stand it did opposing
fluoridation of drinking water supplies. Our union is comprised
of and represents the approximately 1500 scientists, lawyers,
engineers and other professional employees at EPA Headquarters
here in Washington, D.C.

The union first became
interested in this issue rather by accident. Like most Americans,
including many physicians and dentists, most of our members had
thought that fluorides only effects were beneficial -
reductions in tooth decay, etc. We too believed assurances of
safety and effectiveness of water fluoridation.

Then, as EPA was engaged in
revising its drinking water standard for fluoride in 1985, an
employee came to the union with a complaint: he said he was being
forced to write into the regulation a statement to the effect
that EPA thought it was alright for children to have
"funky" teeth. It was OK, EPA said, because it
considered that condition to be only a cosmetic effect,
not an adverse health effect. The reason for this EPA
position was that it was under political pressure to set its
health-based standard for fluoride at 4 mg/liter. At that level,
EPA knew that a significant number of children develop moderate
to severe dental fluorosis, but since it had deemed the effect as
only cosmetic, EPA didnt have to set its health-based
standard at a lower level to prevent it.

We tried to settle this ethics
issue quietly, within the family, but EPA was unable or unwilling
to resist external political pressure, and we took the fight
public with a union amicus curiae brief in a lawsuit filed
against EPA by a public interest group. The union has published
on this initial involvement period in detail.\1

Since then our opposition to
drinking water fluoridation has grown, based on the scientific
literature documenting the increasingly out-of-control exposures
to fluoride, the lack of benefit to dental health from ingestion
of fluoride and the hazards to human health from such ingestion.
These hazards include acute toxic hazard, such as to people with
impaired kidney function, as well as chronic toxic hazards of
gene mutations, cancer, reproductive effects, neurotoxicity, bone
pathology and dental fluorosis. First, a review of recent
neurotoxicity research results.

In 1995, Mullenix and
co-workers \2 showed that rats given fluoride in drinking
water at levels that give rise to plasma fluoride concentrations
in the range seen in humans suffer neurotoxic effects that vary
according to when the rats were given the fluoride - as adult
animals, as young animals, or through the placenta before birth.
Those exposed before birth were born hyperactive and remained so
throughout their lives. Those exposed as young or adult animals
displayed depressed activity. Then in 1998, Guan and co-workers \3 gave doses similar to those used by the Mullenix research group
to try to understand the mechanism(s) underlying the effects seen
by the Mullenix group. Guans group found that several key
chemicals in the brain - those that form the membrane of brain
cells - were substantially depleted in rats given fluoride, as
compared to those who did not get fluoride.

Another 1998 publication by
Varner, Jensen and others \4 reported on the brain- and
kidney damaging effects in rats that were given fluoride in
drinking water at the same level deemed "optimal" by
pro-fluoridation groups, namely 1 part per million (1 ppm). Even
more pronounced damage was seen in animals that got the fluoride
in conjunction with aluminum. These results are especially
disturbing because of the low dose level of fluoride that shows
the toxic effect in rats - rats are more resistant to fluoride
than humans. This latter statement is based on Mullenixs
finding that it takes substantially more fluoride in the drinking
water of rats than of humans to reach the same fluoride level in
plasma. It is the level in plasma that determines how much
fluoride is "seen" by particular tissues in the body.
So when rats get 1 ppm in drinking water, their brains and
kidneys are exposed to much less fluoride than humans getting 1
ppm, yet they are experiencing toxic effects. Thus we are
compelled to consider the likelihood that humans are experiencing
damage to their brains and kidneys at the "optimal"
level of 1 ppm.

In support of this concern are
results from two epidemiology studies from China\5,\6 that show decreases in I.Q. in children who get more fluoride
than the control groups of children in each study. These
decreases are about 5 to 10 I.Q. points in children aged 8 to 13
years.

Another troubling brain effect
has recently surfaced: fluorides interference with the
function of the brains pineal gland. The pineal gland
produces melatonin which, among other roles, mediates the
bodys internal clock, doing such things as governing the
onset of puberty. Jennifer Luke\7 has shown that fluoride
accumulates in the pineal gland and inhibits its production of
melatonin. She showed in test animals that this inhibition causes
an earlier onset of sexual maturity, an effect reported in humans
as well in 1956, as part of the Kingston/Newburgh study, which is
discussed below. In fluoridated Newburgh, young girls experienced
earlier onset of menstruation (on average, by six months) than
girls in non-fluoridated Kingston \8.

From a risk assessment
perspective, all these brain effect data are particularly
compelling and disturbing because they are convergent.

We looked at the cancer data
with alarm as well. There are epidemiology studies that are
convergent with whole-animal and single-cell studies (dealing
with the cancer hazard), just as the neurotoxicity research just
mentioned all points in the same direction. EPA fired the Office
of Drinking Waters chief toxicologist, Dr. William Marcus,
who also was our local unions treasurer at the time, for
refusing to remain silent on the cancer risk issue\9 . The
judge who heard the lawsuit he brought against EPA over the
firing made that finding - that EPA fired him over his fluoride
work and not for the phony reason put forward by EPA management
at his dismissal. Dr. Marcus won his lawsuit and is again at work
at EPA. Documentation is available on request.

The type of cancer of
particular concern with fluoride, although not the only type, is
osteosarcoma, especially in males. The National Toxicology
Program conducted a two-year study \10 in which rats and
mice were given sodium fluoride in drinking water. The positive
result of that study (in which malignancies in tissues other than
bone were also observed), particularly in male rats, is
convergent with a host of data from tests showing fluorides
ability to cause mutations (a principal "trigger"
mechanism for inducing a cell to become cancerous) e.g.\11a,
b, c, d and data showing increases in osteosarcomas in young
men in New Jersey \12 , Washington and Iowa \13 based on their drinking fluoridated water. It was his analysis,
repeated statements about all these and other incriminating
cancer data, and his requests for an independent, unbiased
evaluation of them that got Dr. Marcus fired.

Bone pathology other than
cancer is a concern as well. An excellent review of this issue
was published by Diesendorf et al. in 1997 \14. Five
epidemiology studies have shown a higher rate of hip fractures in
fluoridated vs. non-fluoridated communities. \15a, b, c, d, e. Crippling skeletal fluorosis was the endpoint used by EPA to set
its primary drinking water standard in 1986, and the ethical
deficiencies in that standard setting process prompted our union
to join the Natural Resources Defense Council in opposing the
standard in court, as mentioned above.

Regarding the effectiveness of
fluoride in reducing dental cavities, there has not been any
double-blind study of fluorides effectiveness as a caries
preventative. There have been many, many small scale, selective
publications on this issue that proponents cite to justify
fluoridation, but the largest and most comprehensive study, one
done by dentists trained by the National Institute of Dental
Research, on over 39,000 school children aged 5-17 years, shows
no significant differences (in terms of decayed, missing and
filled teeth) among caries incidences in fluoridated,
non-fluoridated and partially fluoridated communities.\16.
The latest publication \17 on the fifty-year fluoridation
experiment in two New York cities, Newburgh and Kingston, shows
the same thing. The only significant difference in dental health
between the two communities as a whole is that fluoridated
Newburgh, N.Y. shows about twice the incidence of dental
fluorosis (the first, visible sign of fluoride chronic toxicity)
as seen in non-fluoridated Kingston.

John Colquhouns
publication on this point of efficacy is especially important\18.
Dr. Colquhoun was Principal Dental Officer for Auckland, the
largest city in New Zealand, and a staunch supporter of
fluoridation - until he was given the task of looking at the
world-wide data on fluoridations effectiveness in
preventing cavities. The paper is titled, "Why I changed My
Mind About Water Fluoridation." In it Colquhoun provides
details on how data were manipulated to support fluoridation in
English speaking countries, especially the U.S. and New Zealand.
This paper explains why an ethical public health professional was
compelled to do a 180 degree turn on fluoridation.

Further on the point of the
tide turning against drinking water fluoridation, statements are
now coming from other dentists in the pro-fluoride camp who are
starting to warn that topical fluoride (e.g. fluoride in tooth
paste) is the only significantly beneficial way in which that
substance affects dental health \19, \20, \21.
However, if the concentrations of fluoride in the oral cavity are
sufficient to inhibit bacterial enzymes and cause other
bacteriostatic effects, then those concentrations are also
capable of producing adverse effects in mammalian tissue, which
likewise relies on enzyme systems. This statement is based not
only on common sense, but also on results of mutation studies
which show that fluoride can cause gene mutations in mammalian
and lower order tissues at fluoride concentrations estimated to
be present in the mouth from fluoridated tooth paste\22.
Further, there were tumors of the oral cavity seen in the NTP
cancer study mentioned above, further strengthening concern over
the toxicity of topically applied fluoride.

In any event, a person can
choose whether to use fluoridated tooth paste or not (although
finding non-fluoridated kinds is getting harder and harder), but
one cannot avoid fluoride when it is put into the public water
supplies.

So, in addition to our concern
over the toxicity of fluoride, we note the uncontrolled - and
apparently uncontrollable - exposures to fluoride that are
occurring nationwide via drinking water, processed foods,
fluoride pesticide residues and dental care products. A recent
report in the lay media\23, that, according to the Centers
for Disease Control, at least 22 percent of Americas
children now have dental fluorosis, is just one indication of
this uncontrolled, excess exposure. The finding of nearly 12
percent incidence of dental fluorosis among children in
un-fluoridated Kingston New York\17 is another. For
governmental and other organizations to continue to push for more exposure in the face of current levels of over-exposure coupled
with an increasing crescendo of adverse toxicity findings is
irrational and irresponsible at best.

Thus, we took the stand that a
policy which makes the public water supply a vehicle for
disseminating this toxic and prophylactically useless (via
ingestion, at any rate) substance is wrong.

We have also taken a direct
step to protect the employees we represent from the risks of
drinking fluoridated water. We applied EPAs risk control
methodology, the Reference Dose, to the recent neurotoxicity
data. The Reference Dose is the daily dose, expressed in
milligrams of chemical per kilogram of body weight, that a person
can receive over the long term with reasonable assurance of
safety from adverse effects. Application of this methodology to
the Varner et al.\4 data leads to a Reference Dose for
fluoride of 0.000007 mg/kg-day. Persons who drink about one quart
of fluoridated water from the public drinking water supply of the
District of Columbia while at work receive about 0.001mg/kg-day
from that source alone. This amount of fluoride is more than 100
times the Reference Dose. On the basis of these results the union
filed a grievance, asking that EPA provide un-fluoridated
drinking water to its employees.

The implication for the
general public of these calculations is clear. Recent,
peer-reviewed toxicity data, when applied to EPAs standard
method for controlling risks from toxic chemicals, require an
immediate halt to the use of the nations drinking water
reservoirs as disposal sites for the toxic waste of the phosphate
fertilizer industry\24.

__________________________

This document was prepared on
behalf of the National Treasury Employees Union Chapter 280 by
Chapter Senior Vice-President J. William Hirzy, Ph.D. For more
information please call Dr. Hirzy at 202-260-4683. His E-mail
address is <hirzy.john@epa.gov>

END NOTE LITERATURE
CITATIONS

1.Applying the NAEP code of
ethics to the Environmental Protection Agency and the fluoride in
drinking water standard. Carton, R.J. and Hirzy, J.W. Proceedings
of the 23rd Ann. Conf. of the National Association of
Environmental Professionals. 20-24 June, 1998. GEN 51-61.
On-line at URL http//:www.rvi.net/~fluoride/naep.htm

15c. The association between
water fluoridation and hip fracture among white women and men
aged 65 years and older: a national ecological study. Jacobsen,
S.J., Goldberg, J., Cooper, C. and Lockwood, S.A. Ann.
Epidemiol.2 617-626 (1992).

19. A re-examination of the
pre-eruptive and post-eruptive mechanism of the anti-caries
effects of fluoride: is there any anti-caries benefit from
swallowing fluoride? Limeback, H. Community Dent. Oral
Epidemiol.27 62-71 (1999).

20. Fluoride supplements for
young children: an analysis of the literature focussing on
benefits and risks. Riordan, P.J. Community Dent. Oral
Epidemiol.27 72-83 (1999).